According to your front-page news item, Government to stand by waiving of Crowne Plaza EIA, (TMID, 3 July), our government has decided to support Mepa’s decision to waive the requirement for an Environmental Impact Assessment (EIA) study on the ex-Crowne Plaza site. This is in response to the threat of a letter of formal notice from the European Commission on the matter. It appears that the government proposes to “explain the procedures this project was subjected to and showing that the decision taken was based on sound criteria and was not an arbitrary one.”

Mepa exempted this project on the basis of a list of reasons, most of which are blatantly biased in favour of the development and go diametrically against local residents’ rights for an acceptable quality of life. What would normally constitute major negative impacts are categorised as “minor negative” by little more than the stroke of a pen, with no indication of data to support the conclusions.

In particular, the devastating environmental consequences of the addition of nearly 400 apartments in an already-overbuilt area with no access except through the already-congested traffic conditions of Sliema – and its attendant pollution – is overlooked. There is no mention of air-quality testing. It is to be noted here that traffic pollution in Sliema has been steadily increasing since 2005. The report contains no indication about possible infrastructural repercussions, particularly in respect of drainage. It is a known fact that the sewerage infrastructure in Sliema struggles to keep up with the current load, let alone that additional load that this massive development will generate.

According to the report, Mepa “studied” the “information from the developer” and “determined” that this was an “exceptional” case which exempts it from the provisions laid down in the directive. Since information from the developer is bound to be biased in favour of the project, how can such information be referred to as “sound criteria”? Furthermore, what proof of the validity of the screening process (if any) do we have? In what way did the screening process reveal “no significant environmental effects”?

According to the report, exemption from an EIA is justified on the basis that “EIAs (had been) carried out for the larger construction projects in the immediate vicinity of the former Crowne Plaza Hotel site, such as for the MIDI project at Tigné Point.” While recognising the fact that such an EIA may provide some background data on the Sliema peninsula, one cannot, with any stretch of the imagination, conclude that this information is sufficient to take an informed decision on the Fort Cambridge development, since this EIA could not possibly take into account the additional cumulative impact of other massive projects added on to the effect of the MIDI project.

Moreover, although single projects, when treated in isolation, may not result in significant impacts, the EU EIA Directive stipulates the need for an assessment of the “cumulative” impacts. The additional impacts arising as a consequence of the Fort Cambridge development can never be assessed by EIAs conducted for previous projects!

This hugely important factor has been simply bypassed by Mepa through incorrectly claiming that the existing EIA covers the new project. It does not. It so happens that Mepa resorted to precisely the same deception as in Ramla l-Hamra – where a report written for another purpose was passed off as an “EIA”.

Other major flaws to this argument include the fact that the MIDI project was based on the provision of a two-way tunnel carrying traffic off the streets, while it now transpires that the tunnel has suddenly narrowed to one way, leaving the west-side incoming traffic to jam the streets even more and to choke the residents. The final traffic management arrangement, which was hurriedly completed at the last moment – when the end permit was virtually a foregone conclusion – was not shown to the public before the hearing.

To conclude that any visual impacts are “not expected to be significant” is simply outrageous. Photographic evidence shows that the high-rise structures will tower over the Valletta bastion skyline when seen from Vittoriosa. This denial of the visual impact is an insult to the public.

The flimsiness and superficiality of the government’s counter-arguments to the impending letter of formal notice from the European Commission are betrayed by vague phrases such as “not likely to have significant effects on the environment” and sloppy reasoning – a prime example of which is that any incremental impacts “would not be significant, particularly as the area is a residential area”. The situation is exactly the opposite; the impact will be all the more severe precisely because the area is already densely residential. And, surely, to say that significant effects on the environment are “not likely” is not very reassuring – this alone constitutes grounds for a properly-conducted EIA.

George G. Debono

Flimkien ghal-Ambjent Ahjar

Sliema